Greetings. Following review and editing by the Executive Committee, once again on very short notice (thanks to the EC for it), we filed yesterday evening the attached Reply, essentially only to the WCS Coalition. This is a complicated pleading to read, but the issue is rather simple actually. We had asked the FCC to confirm two things, and if they couldn't do it, then we asked them to reconsider the order in this proceeding. You will recall that the FCC allowed mobile (read mobile broadband) devices in addition to fixed path systems in the 2305-2320 and 2345-2360 MHz bands. (In between these two bands, by the way, is the Sirius/XM Digital Audio Broadcast band; Sirius/XM has it even worse as a result of this action than we do). The two points we wanted confirmed by FCC were that (1) the out of band emission limits that FCC continued to specify for WCS mobile and fixed devices below their band edge of 2305 MHz applied throughout the entirety of the 2300-2305 MHz band; and (2) notwithstanding the OOBE limits, if nevertheless there was interference to Amateur operations in the 2300-2305 MHz band from WCS operation above 2305 MHz, it is the obligation of the WCS operator to resolve the interference. As to item #1, the WCS coalition in essence agreed with us. With respect to #2, they opposed us, claiming that because we are secondary at 2300-2305 MHz and they are primary ABOVE 2305 MHz, they don't have to protect us. That is a ludicrous argument, and we are helped by an FCC rule that specifically says what we urged FCC to clarify. That rule comes from the International Radio Regulations, which binds FCC. So, keep that explanation in mind when you read the hyptertechnical/hyperlegal argument in this filing. Thanks to the EC for the fast review and approval of this, and thanks especially to Dave Sumner for some critically important and helpful edits. We have gotten an "attaboy" on this from the Wiley Rein firm which represents Sirus/XM, so we are feeling pretty good about this, but keep in mind that we are up against the FCC mobile broadband juggernaut, so all bets are off in predicting outcomes. We will see what FCC does with this. 73, Chris W3KD Christopher D. Imlay Booth, Freret, Imlay & Tepper. P.C. 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD@ARRL.ORG